PRIVACY POLICY IN ACCORDANCE WITH GDPR UE 2016/679

Welcome to our website. Please read our privacy policy carefully, which applies both if you access the website and simply decide to browse it and if you use advanced Services. This information is provided pursuant to the European Regulation for the Protection of Personal Data (General Data Protection Regulation, also GDPR) 2016/679, which provides protection of individuals with respect to the processing of Personal Data. According to this legislation, this treatment will be based on lawfulness and transparency and the protection of your privacy and your rights.

 

Privacy Policy

 

Data Owner

Graper Srl

Partita IVA/Codice Fiscale: 08021120723

Via Fratelli Coletta, 16 – 70014 – Conversano (BA)

Tel. +39 080 64 50 219 – email info@graper.it

 

Types of data collected

Among the Personal Data collected, either independently or through third parties, there are: cookies, usage data, email, various types of data, telephone number, country, city, province.
Complete details on each type of data collected are provided in the dedicated sections of this privacy policy or through specific information texts displayed before the data is collected.
Personal Data may be freely provided by the User or, in the case of usage data, collected automatically when using the portal.
Unless otherwise specified, all the requested data are mandatory. If the User refuses to provide them, it may be impossible to provide the Service. In cases in which the portal indicates some data as optional, the Users are free to refrain from communicating such data, without this having any consequence on the availability of the Service or on its operation.
Users who have doubts about which data are mandatory are encouraged to contact the Owner.
Any use of Cookies – or other tracking tools – by the portal or by the Owners of third party Services used by the portal, unless otherwise specified, has the purpose of providing the Service requested by the User, in addition to the additional purposes described in this document and in the cookie policy, if available. The User assumes responsibility for the Personal Data of third parties obtained, published or shared through the portal and guarantees to have the right to communicate or disseminate them, freeing the Owner from any liability to third parties.

 

How and where collected data are processed

 

Processing method

The Owner takes appropriate security measures to prevent unauthorised access, disclosure, modification or destruction of Personal Data.
The processing is carried out using telematic tools, with methods and logic strictly related to the purposes indicated.
In addition to the Owner, in some cases, other subjects involved in the organisation (administrative, commercial, marketing, legal, system administrators) which means external subjects (such as third party technical Service providers, postal couriers, hosting providers. IT companies, communication agencies, consultancy agencies) may have access to the Data , and they are also appointed, if necessary, as Data Processors by the Owner. The updated list of Managers can always be requested from the Data Controller.

 

Legal basis for the processing

The Data Controller processes Personal Data relating to the User if one of the following conditions exists:

  • the User has given consent for one or more specific purposes; Note: in some jurisdictions the Data Controller may be authorised to process Personal Data without the User’s consent or another of the legal bases specified below, as long as the User does not agree (“opt-out”) to such treatment. However, this is not applicable if the processing of Personal Data is governed by the European legislation on the protection of Personal Data;
  • the processing is necessary for the execution of a contract with the User and / or for the execution of pre-contractual measures;
  • the processing is necessary to fulfil a legal obligation to which the data controller is subject;
  • the processing is necessary for the performance of a task of public interest or for the exercise of public authority vested in the Owner;
  • the processing is necessary for the pursuit of the legitimate interest of the data controller or third parties.

However, it is always possible to ask the Data Controller to clarify the concrete legal basis of each treatment and in particular to specify whether the treatment is based on the law, provided by a contract or necessary to finalise a contract.

 

Processing places

The data is processed at the Data Controller’s operating offices and in any other place where the parties involved in the processing are located. For more information, please contact the Data Controller.
The User’s Personal Data may be transferred to a country other than that in which the User is located. To obtain further information on the place of processing, the User can refer to the section relating to the details on the processing of Personal Data.
The User has the right to obtain information regarding the legal basis for the transfer of data outside the European Union or to an international organisation governed by public international law or consisting of two or more countries, such as the UN, as well as regarding the security measures adopted by the Data Controller to protect the Data.
If one of the transfers described above takes place, the User can refer to the respective sections of this document or request information from the Data Controller by contacting him at the opening details.

 

Retention period

The Data are processed and stored for the time required by the purposes for which they were collected.
Therefore:
Personal Data collected for purposes related to the execution of a contract between the Owner and the User will be retained until the execution of this contract is completed.
Personal Data collected for purposes related to the legitimate interest of the data controller will be retained until this interest is satisfied. The User can obtain further information regarding the legitimate interest pursued by the Owner in the relevant sections of this document or by contacting the Owner.
When the processing is based on the User’s consent, the Data Controller may keep the Personal Data longer until such consent is revoked. Furthermore, the Data Controller may be obliged to keep Personal Data for a longer period in compliance with a legal obligation or by order of an authority.
At the end of the retention period, the Personal Data will be deleted. Therefore, at the end of this term the right of access, cancellation, rectification and the right to data portability can no longer be exercised.

 

Purpose of processing of collected Data

The User’s data is collected to allow the Owner to provide its Services, as well as for the following purposes: Statistics, remarketing and behavioural targeting, Management of support and contact requests, content and functionality performance tests (A / B testing), contact the User, social features, User database management, tag management, Heat mapping and session recording, hosting and backend infrastructure, interaction with online survey platforms, Interaction with data collection platforms and other third parties, infrastructure monitoring and contact management and sending messages.
To obtain further detailed information on the purposes of the processing and on the Personal Data concretely relevant to each purpose, the User can refer to the relevant sections of this document.

 

Details on processing Personal Data 

Personal Data is collected for the following purposes and using the following Services:

 

Contact the User

Social features

Contact management and sending messages

This type of Service allows you to manage a database of email contacts, telephone contacts or contacts of any other type, used to communicate with the User.
These Services may also allow the collection of data relating to the date and time the messages are displayed by the User, as well as the User’s interaction with them, such as information on clicks on links inserted in messages.

 

Management of support and contact

This type of Service allows the portal to manage the support and contact request received via mail or other tools, such as the contact form
The processed Personal Data depends on the information given by the User in the messages and the tool used to communicate (email address, for example).

 

Hosting and backend infrastructure

This type of Service has the function of hosting Data and files that allow the portal to function, its distribution and provide a ready-to-use infrastructure to provide specific portal features.
Some of these Services work through servers geographically located in different places, making it difficult to determine the exact place where Personal Data is stored.

 

Interaction with data collection platforms and third parties

This type of Service allows Users to interact with data collection platforms or other Services directly from the portal pages in order to save and reuse data.
In the event that one of these Services is installed, it is possible that, even if the Users do not use the Service, it collects Usage Data relating to the pages in which it is installed.

 

Infrastructure monitoring

This type of Service allows the portal to monitor the use and behaviour of its components to improve performance and functionality, maintenance or troubleshooting.
The Personal Data processed depend on the characteristics and methods of implementation of these Services, which by their nature filter the activity of the portal.

 

Statistics

The Services contained in this section allow the Data Controller to monitor and analyse traffic data and are used to keep track of User behaviour.

 

Google Analytics (Google Ireland Limited)

Google Analytics is a web analytics Service provided by Google Ireland Limited. Google uses the Personal Data collected for the purpose of tracking and examining the use of the portal, compiling reports and sharing them with other Services developed by Google.
Google may use the Personal Data to contextualise and personalise the advertisements of its own advertising network.

Facebook Analytics for Apps (Facebook, Inc.)

Facebook Analytics for Apps is a statistics Service provided by Facebook, Inc.
Personal Data collected: Usage data and various types of Data as specified in the privacy policy of the Service.

 

Unique device identification

The portal can track Users by saving a unique identification code of their device, for statistical purposes or to store Users’ preferences.

 

User rights

Users can exercise certain rights with reference to the Data processed by the Data Controller.

In particular, the User has the right to:

  • withdraw consent at any time. The User can overrule the consent to the processing of their Personal Data previously expressed.
  • oppose the processing of their Data. The User can oppose the processing of their Data when it occurs on a legal basis other than consent. Further details on the right to object are indicated in the section below.
  • access their Data.  The User has the right to obtain information on the data processed by the Data Controller, on certain aspects of the processing and to receive a copy of the Data processed.
  • verify and request rectification. The User can verify the correctness of their data and request its updating or correction
  • obtain the limitation of the treatment. When certain conditions are met, the User can request the limitation of the processing of their Data. In this case, the Data Controller will not process the Data for any other purpose than their conservation
  • obtain the cancellation or removal of their Personal Data. When certain conditions are met, the User can request the cancellation of their Data by the Owner
  • receive their Data or have them transferred to another Owner. The User has the right to receive his / her Data in a structured format, commonly used and readable by an automatic device and, where technically feasible, to obtain its unhindered transfer to another Owner. This provision is applicable when the Data is processed with automated tools and the processing is based on the User’s consent, on a contract to which the User is a party or on contractual measures connected to it
  • propose a complaint. The User can lodge a complaint with the competent Personal Data protection supervisory authority or take legal action

Details on the right to object

When Personal Data are processed in the public interest, in the exercise of public authority vested in the Owner or to pursue a legitimate interest of the Owner, Users have the right to object to the processing for reasons related to their particular situation.
Users are reminded that, if their data are processed for direct marketing purposes, they can oppose the processing without providing any reasons. To find out if the Data Controller processes Data for direct marketing purposes, Users can refer to the respective sections of this document.

 

How to exercise the rights

To exercise the User’s rights, Users can address a request to the contact details of the Data Controller indicated in this document. Requests are filed free of charge and processed by the Data Controller as soon as possible, in any case within a month.